Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Order Approving Proposed Rule Change To Amend Rule 12400 of the Code of Arbitration Procedure for Customer Disputes and Rule 13400 of the Code of Arbitration Procedure for Industry Disputes Relating To Broadening Chairperson Eligibility in Arbitration, 88720-88724 [2016-29385]
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those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549 on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of such
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–
NASDAQ–2016–162, and should be
submitted on or before December 29,
2016.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.13
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2016–29386 Filed 12–7–16; 8:45 am]
BILLING CODE 8011–01–P
Customer Code, ‘‘Codes’’).3 The
proposed rule change would allow an
attorney arbitrator to qualify for the
chairperson roster if he or she completes
chairperson training and serves as an
arbitrator through award on at least one
arbitration. The Codes currently require
that an attorney must serve as arbitrator
through award on at least two
arbitrations in order to qualify for the
chairperson roster.
The proposed rule change was
published for comment in the Federal
Register on September 6, 2016.4 The
public comment period closed on
September 27, 2016. The Commission
received five (5) comment letters on the
proposed amendments.5 On October 14,
2016, FINRA extended the time period
in which the Commission must approve
the proposed rule change, disapprove
the proposed rule change, or institute
proceedings to determine whether to
approve or disapprove the proposed
rule change to December 5, 2016.6 On
November 22, 2016, FINRA responded
to the comment letters received in
response to the Notice.7 This order
approves the proposed rule change.
II. Description of the Proposed Rule
Change 8
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–79455; File No. SR–FINRA–
2016–033]
Background
FINRA arbitrators possess the broad
authority to ‘‘interpret and determine
3 See
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Order Approving
Proposed Rule Change To Amend Rule
12400 of the Code of Arbitration
Procedure for Customer Disputes and
Rule 13400 of the Code of Arbitration
Procedure for Industry Disputes
Relating To Broadening Chairperson
Eligibility in Arbitration
December 2, 2016.
sradovich on DSK3GMQ082PROD with NOTICES
I. Introduction
On August 18, 2016, Financial
Industry Regulatory Authority, Inc.
(‘‘FINRA’’) filed with the Securities and
Exchange Commission (‘‘Commission’’),
pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Exchange Act’’) 1 and Rule 19b–4
thereunder,2 a proposed rule change to
amend Rules 12400 of the Code of
Arbitration Procedure for Customer
Disputes (‘‘Customer Code’’) and Rule
13400 of the Code of Arbitration
Procedure for Industry Disputes
(‘‘Industry Code’’ and, together with the
13 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
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File No. SR–FINRA–2016–033.
Exchange Act Release No. 78729 (Aug. 30,
2016); 81 FR 61288 (Sept. 6, 2016) (‘‘Notice’’).
5 See Letters from Steven B. Caruso, Esq., Maddox
Hargett Caruso, P.C. (Aug. 31, 2016) (‘‘Caruso
Letter’’); Ryan K. Bakhtiari, Aidikoff, Uhl and
Bakhtiari (Sept. 9, 2016) (‘‘Bakhtiari Letter’’); Hugh
Berkson, President, Public Investors Arbitration Bar
Association (‘‘PIABA’’) (Sept. 23, 2016) (‘‘PIABA
Letter’’); Nicole Iannarone, Asst. Clinical Professor,
and Geoffrey R. Hafer, Student Intern, Investor
Advocacy Clinic, Georgia State University College
of Law (‘‘GSU’’) (Sept. 26, 2016) (‘‘GSU Letter’’);
and David T. Bellaire, Esq., Executive Vice
President and General Counsel, Financial Services
Institute (‘‘FSI’’) (Sept. 27, 2016) (‘‘FSI Letter’’). The
comment letters are available on FINRA’s Web site
at https://www.finra.org, at the principal office of
FINRA, at the Commission’s Web site at https://
www.sec.gov/comments/sr-finra-2016-033/
finra2016033.shtml, and at the Commission’s Public
Reference Room.
6 See Letter from Margo A. Hassan, Associate
Chief Counsel, FINRA, to Lourdes Gonzalez,
Assistant Chief Counsel—Sales Practices, Division
of Trading and Markets, Securities and Exchange
Commission, dated October 14, 2016.
7 See Letter from Margo A. Hassan, Associate
Chief Counsel, FINRA, to Brent J. Fields, Secretary,
Securities and Exchange the Commission, dated
November 22, 2016 (‘‘FINRA Letter’’). The FINRA
Letter is available on FINRA’s Web site at https://
www.finra.org, at the principal office of FINRA, at
the Commission’s Web site at https://www.sec.gov/
comments/sr-finra-2016-033/finra2016033.shtml,
and at the Commission’s Public Reference Room.
8 The subsequent description of the proposed rule
change is substantially excerpted from FINRA’s
description in the Notice. See Notice, 81 FR at
61288–61289.
4 See
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the applicability of all provisions under
the Code[s]. Such interpretations are
final and binding upon the parties.’’ 9 To
facilitate the fair administration of
proceedings in the FINRA forum,
arbitrators must possess sufficient
qualifications and participate in
appropriate training 10—particularly
where an arbitrator presides over the
proceeding as chairperson, with the
authority to, among other things, direct
witness appearances, order the
production of documents and
information, and set deadlines in a
given case.11
FINRA maintains a roster of nonpublic arbitrators,12 public arbitrators,13
and arbitrators who are eligible to serve
as chairperson in each of its 71 hearing
locations.14 FINRA employs its
computerized Neutral List Selection
System to randomly generate lists of
potential arbitrators for each proceeding
from these rosters.15 The parties then
select their arbitrators through a process
of striking and ranking the names on the
list generated by the Neutral List
Selection System.16
The Codes provide that arbitrators are
eligible for the chairperson roster if they
have completed chairperson training
provided by FINRA and:
• Have a law degree and are a
member of a bar of at least one
jurisdiction, and have served as an
arbitrator through award on at least two
arbitrations administered by a selfregulatory organization in which
hearings were held; or
• Have served as an arbitrator through
award on at least three arbitrations
administered by a self-regulatory
organization in which hearings were
held.17
Additionally, in customer disputes,
chairpersons must be public
arbitrators.18
In February 2015, the Commission
approved a proposal by FINRA to
amend its definition of ‘‘public
arbitrator,’’ 19 The amended definition
9 See FINRA Rules 12409 (Jurisdiction of Panel
and Authority to Interpret the Code) and 13413
(Jurisdiction of Panel and Authority to Interpret the
Code).
10 See Notice, 81 FR 61289.
11 See FINRA Office of Dispute Resolution
Arbitrator’s Guide (Oct. 2016), at page 31, available
at https://www.finra.org/sites/default/files/
arbitrators-ref-guide.pdf.
12 For the definition of ‘‘non-public arbitrator,’’
see FINRA Rules 12100(p) and 13100(p).
13 For the definition of ‘‘public arbitrator,’’ see
FINRA Rules 12100(u) and 13100(u).
14 See FINRA Rules 12400(b) and 13400(b).
15 See FINRA Rules 12400(a) and 13400(a).
16 Id.
17 See FINRA Rules 12400(c) and 13400(c).
18 See FINRA Rule 12400(c).
19 See Exchange Act Release No. 74383 (Feb. 26,
2015), 80 FR 11695 (Mar. 4, 2015) (Order Approving
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took effect in June 2015,20 resulting in
the reclassification of approximately
13.8 percent of public arbitrators as nonpublic arbitrators, and the rendering of
2.6 percent of its public arbitrator roster
as temporarily disqualified or ineligible
for service.21 Many of the arbitrators
who were reclassified or disqualified
had been chair-qualified prior to the
amendment.22 Currently, FINRA’s
rosters contain approximately 6,750
arbitrators, of which 3,060 are currently
classified as public. Of those classified
as public arbitrators, approximately
1,000 are deemed chair-qualified.23
FINRA contends that forum users
have complained about the diminished
availability of public chairpersons after
the amendment to the public arbitrator
definition. FINRA also states that forum
users have complained of scheduling
difficulties and additional costs
associated with traveling chairpersons
(i.e., public chairpersons that FINRA
asks to travel to other hearing locations
to expand the roster of available public
chairpersons for a given location), as
well as out-of-town arbitrators’ lack of
familiarity with local venue customs
and procedures.24 Moreover, FINRA
states that it has had limited success in
enrolling new public chairpersons, and
that the need for public chairpersons
could potentially surpass the
availability of public chairpersons who
meet the qualifications under the
existing Codes.25
Proposed Rule Change
sradovich on DSK3GMQ082PROD with NOTICES
FINRA is proposing to amend the
eligibility requirements under the Codes
for arbitrators who seek to qualify as
chairpersons. The amendment would
allow an attorney arbitrator to qualify
for the chairperson roster if he or she
completes chairperson training and
serves as an arbitrator through award on
at least one arbitration administered by
a self-regulatory organization where
hearings are held, instead of two
arbitrations (as is currently required).
FINRA is also proposing to replace the
bullets in Rules 12400 and 13400 with
numbers for ease of citation.
FINRA states that reducing the case
experience requirement for would-be
arbitrators from two arbitrations to one
Filing No. SR–FINRA–2014–028) (in part narrowing
the public arbitrator definition by adding
disqualifications relating to, among other things,
affiliations with the securities industry concerning
an arbitrator’s family member or place of
employment).
20 See Notice, 81 FR 61288.
21 See id.
22 See id.
23 See id.
24 See id.
25 See id.
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arbitration could add more than 270
attorney arbitrators across 59 of its 71
hearing locations, potentially resulting
in a nearly 30 percent increase in the
number of arbitrators who might be
eligible to serve as public chairpersons
once they take chairperson training.26
FINRA also believes that the proposed
rule change would increase the
availability of local chairpersons for
forum users, lowering instances in
which chairpersons must travel, and
ameliorating parties’ concerns regarding
out-of-town arbitrators.27
III. Summary of Comments and
FINRA’s Response
The Commission received five (5)
comment letters on the proposed rule
change,28 and a response letter from
FINRA.29 Three commenters supported
the amendment,30 and two generally
supported the amendment while
advocating for further action.31 FINRA’s
response to commenters’ concerns and
suggestions are incorporated below.
Comment Letters in Support of the
Proposal
As noted above, three commenters
supported FINRA’s proposed
amendments to the Codes. One
commenter stated that the proposal
would ‘‘be a fair, equitable and
reasonable approach that would
facilitate the increased appointment of
local chairpersons to arbitration panels
and, at the same time, would reduce the
necessity for the appointment of out-ofstate chairpersons.’’ 32 A second
commenter supported the proposed
amendment on the ground that it
‘‘would significantly increase the
available number of arbitrators included
on the Chair roster and represents an
important step towards increasing the
probability of drawing local
chairpersons in suburban or remote
hearing locations.’’ 33 A third
commenter supported the proposal
based on its belief that the requirement
of a law degree and participation in one
arbitration through award are reasonable
criteria for a public chair.34
26 See
id. at 61289.
id.
28 See supra note 5.
29 See supra note 7.
30 See Caruso Letter, Bakhtiari Letter, and FSI
Letter.
31 See PIABA Letter and GSU Letter.
32 See Caruso Letter.
33 See Bakhtiari Letter.
34 See FSI Letter.
27 See
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88721
Supportive Comment Letters
Recommending Modifications to the
Proposal
Two comment letters recommended
modifications to the proposal, while
generally expressing support for the
proposal. One commenter stated that
investors would ‘‘benefit from a larger
pool of qualified public chairpersons’’
and generally supported the proposed
rule as ‘‘a positive step in regards to
increasing the number of arbitrators in
proposed chair pools[.]’’ 35 Another
commenter stated that it ‘‘applaud[s]
FINRA’s decision to expand the public
arbitrator chair pool[.]’’ 36 However,
both commenters raised additional
concerns and suggestions for the
proposed amendment.
• Enhancing Transparency of the
Arbitrator Selection Process
One commenter advocated for greater
transparency regarding arbitrators’
backgrounds and qualifications, as well
as greater transparency in the arbitrator
selection process generally in order to
improve investor confidence in FINRA
arbitrators.37 According to this
commenter, FINRA’s current disclosure
system, which provides information
regarding arbitrators’ education,
employment history and potential
conflicts, is insufficient to eliminate the
appearance of impropriety and bias.38
In response, FINRA stated that it
produces a disclosure report reflecting
the prior employment, educational
history, and previous arbitration awards
for every potential arbitrator during the
appointment process.39 FINRA also
requires arbitrators to either certify the
accuracy of the information in the
disclosure report or update the report
when they are appointed to a case.40 In
addition, FINRA reminds arbitrators on
a quarterly basis to review their
disclosure reports and revise them as
needed. Moreover, FINRA stated that it
is revising its disclosure reporting
system to alert parties of the last time
the arbitrator certified the accuracy of
the information contained therein.41
• Use of Out-of-Town Arbitrators and
Recruitment Initiatives
One commenter stated that the overall
reduction in the number of eligible
chairpersons has reduced the pool of
local chairpersons, and caused FINRA
to ask non-local chairpersons to travel to
35 See
PIABA Letter.
GSU Letter.
37 See PIABA Letter.
38 Id.
39 See FINRA Letter.
40 Id.
41 Id.
36 See
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multiple hearing locations.42 This
commenter believes that the use of nonlocal arbitrators has resulted in
inconvenience, delay, and additional
costs to parties, and has led to a
decrease in customer awards because of
non-local arbitrators’ purported bias in
favor of the industry.43 For these
reasons, the commenter suggested that,
to the extent possible, FINRA should
eliminate the use of non-local arbitrators
and increase the size of regional pools—
especially where out-of-state arbitrators
regularly appear on public and chairqualified ranking lists.44
In its response, FINRA stated that it
uses arbitrators in neighboring hearing
locations ‘‘to ensure an effective ratio of
available arbitrators to open cases in
each location[.]’’ 45 For example, ‘‘as an
interim measure, FINRA took steps to
bolster the pool of arbitrators in smaller
hearing locations that were impacted by
the amended public arbitrator definition
by asking chairs from larger hearing
locations . . . if they would be willing
to serve[.]’’ 46 FINRA also stated,
however, that it agrees that it should
increase the size of its public arbitrator
pool, and stated that it has been
‘‘actively recruiting new arbitrators,
paying particular attention to locations
with the greatest need.’’ 47
• Additional Chairperson Training and
Mentorship
One commenter expressed the
concern that the proposed rule change
might sacrifice chairperson quality at
the expense of chairperson quantity, as
‘‘quality pools are paramount to a fair
and equitable arbitration proceeding, as
well as the public investors’ confidence
in the overall arbitration process.’’ 48
The commenter therefore
recommended, in part, that FINRA
adopt a ‘‘Chairperson Mentor program’’
to increase the quality of chair-qualified
arbitrators.49
Another commenter similarly asserted
that, by expanding chairperson
eligibility, the proposed rule change
would reduce arbitrators’ exposure to
live proceedings prior to serving as a
chair.50 To address this reduction in
experience, the commenter proposed
that FINRA ‘‘include in the Office of
Dispute Resolution Chairperson
Training a module or section that
specifically addresses the procedural
and substantive issues that regularly
arise in live arbitration proceedings.’’ 51
Alternatively, the commenter proposed
that FINRA require arbitrators to
observe a live or mock proceeding
before becoming eligible to serve as a
public chair.52
In response, FINRA stated that, earlier
this year, it implemented a chairperson
mentorship program to facilitate
interaction between new chairpersons
and experienced chairpersons.53 In
addition, in November 2016, FINRA
provided arbitrators access to online
workshops that address issues
chairpersons regularly encounter.54
Moreover, FINRA stated that it regularly
invites qualified arbitrators to complete
chairperson training.55
means for increasing the chairperson
roster.
In response, FINRA stated that it had
revisited the 2015 amendments to the
arbitrator definitions and determined
not to change the public arbitrator
definition, as FINRA deemed it
important for public arbitrators to have
no significant affiliation with the
financial industry.62 However, FINRA
noted that a gap exists between the
public and non-public arbitrator
definitions, which excludes otherwise
qualified individuals from service as
arbitrators—often because of family or
co-workers’ affiliations.63 According to
FINRA, in September 2016, its Board of
Governors authorized FINRA to file
with the Commission proposed
amendments to Rules 12100 and 13100
• Simplifying the Arbitrator Application of the Codes to revise the non-public
Process
arbitrator definition.64 These
amendments would define a non-public
One commenter expressed concern
that the arbitrator application process is arbitrator as a person who is otherwise
qualified to serve as an arbitrator, and
‘‘burdensome and intimidating and
is disqualified from classification as a
surely drives away many potential
public arbitrator.65 By closing this gap,
arbitrators which further weakens the
FINRA asserted that it could expand its
number and quality of arbitrators
roster of available arbitrators.66
available in the FINRA system.’’ 56
Accordingly, PIABA suggested that
IV. Discussion and Commission
FINRA simplify the arbitrator
Findings
application process.57
The Commission has carefully
FINRA responded that, in 2017, it
considered the proposal, the comments
plans to replace the ‘‘time-consuming’’
received, and FINRA’s response to the
‘‘Securities Disputes Experience’’
comments. Based on its review of the
section of the arbitrator application with record, the Commission finds that the
a section that allows applicants to
proposed rule change is consistent with
explain their securities disputes
the requirements of the Exchange Act
58
expertise and skills in narrative form.
and the rules and regulations
FINRA believes that this change will
thereunder applicable to a national
simplify the arbitrator application
securities association.67 In particular,
59
process.
the Commission finds that the proposed
rule change is consistent with Section
• Revisiting the ‘‘Public Arbitrator’’
15A(b)(6) of the Exchange Act,68 which
Definition
requires, among other things, that
One commenter cited the 2015
FINRA’s rules be designed to prevent
amendments to the definition of ‘‘Public fraudulent and manipulative acts and
Arbitrator’’ as a significant contributor
practices, to promote just and equitable
to the reduction in the chairperson
principles of trade, and, in general, to
roster overall and disproportionately for protect investors and the public interest.
claimants with smaller claims.60 For
As discussed above, the proposal
instance, GSU stated that there are only
would amend Rules 12400 and 13400 of
40 chair-qualified arbitrators in its
the Codes to allow an attorney arbitrator
primary hearing location, Atlanta.61 The to qualify for the chairperson roster if he
commenter thus recommended that
or she completes chairperson training
FINRA revisit the 2015 amendments to
and serves as an arbitrator through
the public arbitrator definition as a
award on at least one arbitration
administered by a self-regulatory
51 Id.
sradovich on DSK3GMQ082PROD with NOTICES
52 Id.
53 See
42 See
PIABA Letter.
43 See id.
44 See id.
45 See FINRA Letter.
46 Id.
47 Id.
48 See PIABA Letter.
49 Id.
50 See GSU Letter.
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17:28 Dec 07, 2016
62 See
FINRA Letter.
64 Id.
55 Id.
56 See
65 Id.
PIABA Letter.
66 Id.
57 Id.
58 See
67 In approving the proposed rule change, the
Commission has also considered its impact on
efficiency, competition, and capital formation. See
15 U.S.C. 78c(f).
68 15 U.S.C. 78o–3(b)(6).
FINRA Letter.
59 Id.
60 See
GSU Letter.
61 Id.
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FINRA Letter.
63 Id.
54 Id.
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organization where hearings are held,
instead of two arbitrations (as is
currently required). It would also
replace the bullets in Rules 12400 and
13400 with numbers for ease of citation.
The Commission has considered the
five (5) comment letters received on the
proposed rule change,69 along with
FINRA’s response to the comments.70
The Commission acknowledges the
supportive commenters’ positions that
the proposal would ‘‘be a fair, equitable
and reasonable approach that would
facilitate the increased appointment of
local chairpersons to arbitration
panels,’’ 71 that it ‘‘would significantly
increase the available number of
arbitrators included on the Chair roster
and represents an important step
towards increasing the probability of
drawing local chairpersons in suburban
or remote hearing locations,’’ 72 and that
the requirement of a law degree and
participation in one arbitration through
award are reasonable criteria for a
public chair.73 However, the
Commission also acknowledges
commenters’ concerns and
recommended modifications to the
proposal.74 These concerns and
modifications are discussed below.
sradovich on DSK3GMQ082PROD with NOTICES
• Enhancing Transparency of the
Arbitrator Selection Process
The Commission acknowledges the
commenter’s concern that FINRA’s
current disclosure system does not
always eliminate the appearance of
impropriety and bias in the FINRA
arbitration forum, and agrees that
transparency in the arbitrator selection
process improves investor confidence in
FINRA arbitrators.75 However, the
Commission believes that FINRA’s
disclosure reporting system provides
parties with a basis on which to identify
potential arbitrator conflicts and biases.
Moreover, the Commission believes that
by reminding arbitrators to update their
disclosure reports, and notifying parties
of the last date an arbitrator certified the
accuracy of the disclosure report,
FINRA will further help ensure that
parties have up-to-date information on
which to base their arbitrator selections.
• Use of Out-of-Town Arbitrators and
Recruitment Initiatives
The Commission acknowledges the
commenter’s concerns regarding the
inconvenience, delay, and additional
costs caused by the use of non-local
69 See
supra note 5.
supra note 7.
71 See Caruso Letter.
72 See Bakhtiari Letter.
73 See FSI Letter.
74 See PIABA Letter and GSU Letter.
75 See PIABA Letter.
arbitrators.76 However, given the
reported insufficient levels of local
chairpersons in certain hearing
locations,77 the Commission does not
believe it is feasible or practical to
eliminate the use of non-local
arbitrators, as the commenter
suggested.78 Instead, the Commission
acknowledges the necessity of FINRA’s
policy of asking public chairs from
larger, geographically proximate hearing
locations to serve as chairpersons in
regions with insufficient levels of local
qualified chairpersons. The Commission
additionally supports FINRA’s
increased arbitrator recruitment efforts,
and anticipates that such efforts will
eventually result in a broader, more
diverse pool of arbitrator candidates.
• Revisiting the ‘‘Public Arbitrator’’
Definition
The Commission acknowledges the
commenter’s suggestion that FINRA
reconsider the 2015 amendments to the
public arbitrator definition in an effort
to combat the resulting reduction in the
chairperson roster.81 However, at the
time the Commission approved the 2015
amendments to the public arbitrator
definition, the Commission determined
that the approach proposed by FINRA
was appropriate and designed to protect
investors and the public interest,
consistent with Section 15A(b)(6) of the
Exchange Act and the rules and
regulations thereunder.82 Accordingly,
the Commission also gives due regard to
FINRA’s decision not to amend the
• Additional Chairperson Training and definition of public arbitrator at this
Mentorship
time.83 Nevertheless, the Commission
will give appropriate consideration to
With regard to commenters’ concerns
any proposed amendments to FINRA
that the proposed amendment might
Rules 12100 and 13100 to revise the
decrease the quality and experience of
non-public arbitrator definition to
arbitrator chairpersons at the expense of
eliminate any gaps in the Codes’
increasing the quantity of chairpersons,
arbitrator classifications that could
the Commission acknowledges their
expand its roster of available arbitrators.
recommendation that a mentor program
Taking into consideration the
or additional trainings should be
comments and FINRA’s responses, the
79 The
provided to chairpersons.
Commission finds that the proposal is
Commission generally believes that
consistent with the Exchange Act.
FINRA’s implementation of a
Specifically, the Commission believes
chairperson mentorship program, as
that the proposal will help protect
well as its increased provision of and
investors and the public interest by,
focus on arbitrator trainings should
among other things, broadening the
effectively address the commenters’
roster of available arbitrator
concerns.
chairpersons, while preserving the
• Simplifying the Arbitrator Application quality of arbitrators who would serve
Process
as chairpersons. Furthermore, the
Commission believes that FINRA’s
The Commission acknowledges the
responses, as discussed in more detail
concern expressed regarding FINRA’s
above, appropriately addressed
purportedly burdensome and
commenters’ concerns and adequately
intimidating arbitrator application
explained FINRA’s reasons for declining
process, and the potential deterrent
effect the process might have on would- to modify its proposal. Accordingly, the
be arbitrator applicants.80 However, the Commission believes that the approach
proposed by FINRA is appropriate and
Commission believes that a rigorous
designed to protect investors and the
application process is necessary to
public interest, consistent with Section
verify the qualifications of arbitrator
15A(b)(6) of the Exchange Act and the
candidates. Furthermore, the
Commission expects that FINRA’s use of rules and regulations thereunder.
a narrative application section where
V. Conclusion
applicants can explain their securities
It is therefore ordered, pursuant to
disputes expertise and skills will
Section 19(b)(2) of the Exchange Act,84
simplify the arbitrator application
that the proposed rule change (SR–
process without degrading the value of
FINRA–2016–033) be, and hereby is,
the elicited information, thereby
approved.
addressing the commenter’s concern.
70 See
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17:28 Dec 07, 2016
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88723
76 Id.
77 See
FINRA Letter.
PIABA Letter.
79 See PIABA Letter and GSU Letter.
80 See PIABA Letter.
78 See
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81 See
GSU Letter.
80 FR 11695 at 11704–11705.
83 See FINRA Letter.
84 15 U.S.C. 78s(b)(2).
82 See
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For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.85
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2016–29385 Filed 12–7–16; 8:45 am]
BILLING CODE 8011–01–P
SMALL BUSINESS ADMINISTRATION
[Disaster Declaration #14997 and #14998]
Minnesota Disaster #MN–00059
U.S. Small Business
Administration.
ACTION: Notice.
AGENCY:
This is a Notice of the
Presidential declaration of a major
disaster for the State of Minnesota
(FEMA–4290–DR), dated 11/29/2016.
Incident: Severe Storms and Flooding.
Incident Period: 09/21/2016 through
09/24/2016.
Effective Date: 11/29/2016.
Physical Loan Application Deadline
Date: 01/30/2017.
Economic Injury (EIDL) Loan
Application Deadline Date: 08/29/2017.
ADDRESSES: Submit completed loan
applications to: U.S. Small Business
Administration, Processing and
Disbursement Center, 14925 Kingsport
Road, Fort Worth, TX 76155.
FOR FURTHER INFORMATION CONTACT: A.
Escobar, Office of Disaster Assistance,
U.S. Small Business Administration,
409 3rd Street SW., Suite 6050,
Washington, DC 20416.
SUPPLEMENTARY INFORMATION: Notice is
hereby given that as a result of the
President’s major disaster declaration on
11/29/2016, applications for disaster
loans may be filed at the address listed
above or other locally announced
locations.
The following areas have been
determined to be adversely affected by
the disaster:
Primary Counties (Physical Damage and
Economic Injury Loans): Blue Earth,
Freeborn, Hennepin, Le Sueur,
Rice, Steele, Waseca.
Contiguous Counties (Economic Injury
Loans Only):
Minnesota: Anoka, Brown, Carver,
Dakota, Dodge, Faribault, Goodhue,
Martin, Mower, Nicollet, Ramsey,
Scott, Sherburne, Sibley,
Watonwan, Wright.
Iowa: Winnebago, Worth.
The Interest Rates are:
sradovich on DSK3GMQ082PROD with NOTICES
SUMMARY:
Percent
DEPARTMENT OF STATE
[Public Notice: 9808]
Homeowners With Credit Available Elsewhere ......................
Homeowners Without Credit
Available Elsewhere ..............
Businesses With Credit Available Elsewhere ......................
Businesses
Without
Credit
Available Elsewhere ..............
Non-Profit Organizations With
Credit Available Elsewhere ...
NON-Profit Organizations Without Credit Available Elsewhere .....................................
For Economic Injury:
Businesses & Small Agricultural
Cooperatives Without Credit
Available Elsewhere ..............
NON-Profit Organizations Without Credit Available Elsewhere .....................................
3.125
1.563
6.250
Culturally Significant Objects Imported
for Exhibition Determinations:
‘‘Shakespeare in Prague: Imagining the
Bard in the Heart of Europe’’ Exhibition
Notice is hereby given of the
following determinations: Pursuant to
the authority vested in me by the Act of
2.625
October 19, 1965 (79 Stat. 985; 22 U.S.C.
2459), E.O. 12047 of March 27, 1978, the
2.625 Foreign Affairs Reform and
Restructuring Act of 1998 (112 Stat.
2681, et seq.; 22 U.S.C. 6501 note, et
seq.), Delegation of Authority No. 234 of
4.000 October 1, 1999, Delegation of Authority
No. 236–3 of August 28, 2000 (and, as
appropriate, Delegation of Authority No.
2.625 257 of April 15, 2003), I hereby
determine that the objects to be
included in the exhibition ‘‘Shakespeare
The number assigned to this disaster
in Prague: Imagining the Bard in the
for physical damage is 14997B and for
Heart of Europe,’’ imported from abroad
economic injury is 149980.
for temporary exhibition within the
(Catalog of Federal Domestic Assistance
United States, are of cultural
Number 59008)
significance. The objects are imported
pursuant to a loan agreement with the
James E. Rivera,
foreign owner or custodian. I also
Associate Administrator for Disaster
determine that the exhibition or display
Assistance.
of the exhibit objects at the Columbus
[FR Doc. 2016–29382 Filed 12–7–16; 8:45 am]
Museum of Art, Columbus, Ohio, from
BILLING CODE 8025–01–P
on or about February 10, 2017, until on
or about May 21, 2017, at the University
of the Incarnate Word, San Antonio,
SMALL BUSINESS ADMINISTRATION
Texas, from on or about July 10, 2017,
until on or about September 30, 2017,
Surrender of License of Small
and at possible additional exhibitions or
Business Investment Company
venues yet to be determined, is in the
national interest. I have ordered that
Pursuant to the authority granted to
Public Notice of these Determinations
the United States Small Business
be published in the Federal Register.
Administration under the Small
FOR FURTHER INFORMATION CONTACT: For
Business Investment Act of 1958, as
further information, including a list of
amended, under Section 309 of the Act
the imported objects, contact the Office
and Section 107.1900 of the Small
of Public Diplomacy and Public Affairs
in the Office of the Legal Adviser, U.S.
Business Administration Rules and
Department of State (telephone: 202–
Regulations (13 CFR 107.1900) to
function as a small business investment 632–6471; email: section2459@
state.gov). The mailing address is U.S.
company under the Small Business
Department of State, L/PD, SA–5, Suite
Investment Company License No. 04/
5H03, Washington, DC 20522–0505.
04–0304 issued to White Oak SBIC
Fund, L.P., said license is hereby
Mark Taplin,
declared null and void.
Principal Deputy Assistant Secretary, Bureau
4.000
United States Small Business
Administration.
Mark Walsh,
Associate Administrator for Investment and
Innovation.
[FR Doc. 2016–29381 Filed 12–7–16; 8:45 am]
SUMMARY:
of Educational and Cultural Affairs,
Department of State.
[FR Doc. 2016–29401 Filed 12–7–16; 8:45 am]
BILLING CODE 4710–05–P
DEPARTMENT OF TRANSPORTATION
BILLING CODE 8025–01–P
Federal Aviation Administration
Percent
Type Certificates 3A2 and A–772
For Physical Damage:
Federal Aviation
Administration (FAA), DOT.
AGENCY:
85 17
CFR 200.30–3(a)(12).
VerDate Sep<11>2014
17:28 Dec 07, 2016
Jkt 241001
PO 00000
Frm 00068
Fmt 4703
Sfmt 4703
E:\FR\FM\08DEN1.SGM
08DEN1
Agencies
[Federal Register Volume 81, Number 236 (Thursday, December 8, 2016)]
[Notices]
[Pages 88720-88724]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-29385]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-79455; File No. SR-FINRA-2016-033]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Order Approving Proposed Rule Change To Amend Rule
12400 of the Code of Arbitration Procedure for Customer Disputes and
Rule 13400 of the Code of Arbitration Procedure for Industry Disputes
Relating To Broadening Chairperson Eligibility in Arbitration
December 2, 2016.
I. Introduction
On August 18, 2016, Financial Industry Regulatory Authority, Inc.
(``FINRA'') filed with the Securities and Exchange Commission
(``Commission''), pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Exchange Act'') \1\ and Rule 19b-4
thereunder,\2\ a proposed rule change to amend Rules 12400 of the Code
of Arbitration Procedure for Customer Disputes (``Customer Code'') and
Rule 13400 of the Code of Arbitration Procedure for Industry Disputes
(``Industry Code'' and, together with the Customer Code, ``Codes'').\3\
The proposed rule change would allow an attorney arbitrator to qualify
for the chairperson roster if he or she completes chairperson training
and serves as an arbitrator through award on at least one arbitration.
The Codes currently require that an attorney must serve as arbitrator
through award on at least two arbitrations in order to qualify for the
chairperson roster.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See File No. SR-FINRA-2016-033.
---------------------------------------------------------------------------
The proposed rule change was published for comment in the Federal
Register on September 6, 2016.\4\ The public comment period closed on
September 27, 2016. The Commission received five (5) comment letters on
the proposed amendments.\5\ On October 14, 2016, FINRA extended the
time period in which the Commission must approve the proposed rule
change, disapprove the proposed rule change, or institute proceedings
to determine whether to approve or disapprove the proposed rule change
to December 5, 2016.\6\ On November 22, 2016, FINRA responded to the
comment letters received in response to the Notice.\7\ This order
approves the proposed rule change.
---------------------------------------------------------------------------
\4\ See Exchange Act Release No. 78729 (Aug. 30, 2016); 81 FR
61288 (Sept. 6, 2016) (``Notice'').
\5\ See Letters from Steven B. Caruso, Esq., Maddox Hargett
Caruso, P.C. (Aug. 31, 2016) (``Caruso Letter''); Ryan K. Bakhtiari,
Aidikoff, Uhl and Bakhtiari (Sept. 9, 2016) (``Bakhtiari Letter'');
Hugh Berkson, President, Public Investors Arbitration Bar
Association (``PIABA'') (Sept. 23, 2016) (``PIABA Letter''); Nicole
Iannarone, Asst. Clinical Professor, and Geoffrey R. Hafer, Student
Intern, Investor Advocacy Clinic, Georgia State University College
of Law (``GSU'') (Sept. 26, 2016) (``GSU Letter''); and David T.
Bellaire, Esq., Executive Vice President and General Counsel,
Financial Services Institute (``FSI'') (Sept. 27, 2016) (``FSI
Letter''). The comment letters are available on FINRA's Web site at
https://www.finra.org, at the principal office of FINRA, at the
Commission's Web site at https://www.sec.gov/comments/sr-finra-2016-033/finra2016033.shtml, and at the Commission's Public Reference
Room.
\6\ See Letter from Margo A. Hassan, Associate Chief Counsel,
FINRA, to Lourdes Gonzalez, Assistant Chief Counsel--Sales
Practices, Division of Trading and Markets, Securities and Exchange
Commission, dated October 14, 2016.
\7\ See Letter from Margo A. Hassan, Associate Chief Counsel,
FINRA, to Brent J. Fields, Secretary, Securities and Exchange the
Commission, dated November 22, 2016 (``FINRA Letter''). The FINRA
Letter is available on FINRA's Web site at https://www.finra.org, at
the principal office of FINRA, at the Commission's Web site at
https://www.sec.gov/comments/sr-finra-2016-033/finra2016033.shtml,
and at the Commission's Public Reference Room.
---------------------------------------------------------------------------
II. Description of the Proposed Rule Change \8\
---------------------------------------------------------------------------
\8\ The subsequent description of the proposed rule change is
substantially excerpted from FINRA's description in the Notice. See
Notice, 81 FR at 61288-61289.
---------------------------------------------------------------------------
Background
FINRA arbitrators possess the broad authority to ``interpret and
determine the applicability of all provisions under the Code[s]. Such
interpretations are final and binding upon the parties.'' \9\ To
facilitate the fair administration of proceedings in the FINRA forum,
arbitrators must possess sufficient qualifications and participate in
appropriate training \10\--particularly where an arbitrator presides
over the proceeding as chairperson, with the authority to, among other
things, direct witness appearances, order the production of documents
and information, and set deadlines in a given case.\11\
---------------------------------------------------------------------------
\9\ See FINRA Rules 12409 (Jurisdiction of Panel and Authority
to Interpret the Code) and 13413 (Jurisdiction of Panel and
Authority to Interpret the Code).
\10\ See Notice, 81 FR 61289.
\11\ See FINRA Office of Dispute Resolution Arbitrator's Guide
(Oct. 2016), at page 31, available at https://www.finra.org/sites/default/files/arbitrators-ref-guide.pdf.
---------------------------------------------------------------------------
FINRA maintains a roster of non-public arbitrators,\12\ public
arbitrators,\13\ and arbitrators who are eligible to serve as
chairperson in each of its 71 hearing locations.\14\ FINRA employs its
computerized Neutral List Selection System to randomly generate lists
of potential arbitrators for each proceeding from these rosters.\15\
The parties then select their arbitrators through a process of striking
and ranking the names on the list generated by the Neutral List
Selection System.\16\
---------------------------------------------------------------------------
\12\ For the definition of ``non-public arbitrator,'' see FINRA
Rules 12100(p) and 13100(p).
\13\ For the definition of ``public arbitrator,'' see FINRA
Rules 12100(u) and 13100(u).
\14\ See FINRA Rules 12400(b) and 13400(b).
\15\ See FINRA Rules 12400(a) and 13400(a).
\16\ Id.
---------------------------------------------------------------------------
The Codes provide that arbitrators are eligible for the chairperson
roster if they have completed chairperson training provided by FINRA
and:
Have a law degree and are a member of a bar of at least
one jurisdiction, and have served as an arbitrator through award on at
least two arbitrations administered by a self-regulatory organization
in which hearings were held; or
Have served as an arbitrator through award on at least
three arbitrations administered by a self-regulatory organization in
which hearings were held.\17\
---------------------------------------------------------------------------
\17\ See FINRA Rules 12400(c) and 13400(c).
---------------------------------------------------------------------------
Additionally, in customer disputes, chairpersons must be public
arbitrators.\18\
---------------------------------------------------------------------------
\18\ See FINRA Rule 12400(c).
---------------------------------------------------------------------------
In February 2015, the Commission approved a proposal by FINRA to
amend its definition of ``public arbitrator,'' \19\ The amended
definition
[[Page 88721]]
took effect in June 2015,\20\ resulting in the reclassification of
approximately 13.8 percent of public arbitrators as non-public
arbitrators, and the rendering of 2.6 percent of its public arbitrator
roster as temporarily disqualified or ineligible for service.\21\ Many
of the arbitrators who were reclassified or disqualified had been
chair-qualified prior to the amendment.\22\ Currently, FINRA's rosters
contain approximately 6,750 arbitrators, of which 3,060 are currently
classified as public. Of those classified as public arbitrators,
approximately 1,000 are deemed chair-qualified.\23\
---------------------------------------------------------------------------
\19\ See Exchange Act Release No. 74383 (Feb. 26, 2015), 80 FR
11695 (Mar. 4, 2015) (Order Approving Filing No. SR-FINRA-2014-028)
(in part narrowing the public arbitrator definition by adding
disqualifications relating to, among other things, affiliations with
the securities industry concerning an arbitrator's family member or
place of employment).
\20\ See Notice, 81 FR 61288.
\21\ See id.
\22\ See id.
\23\ See id.
---------------------------------------------------------------------------
FINRA contends that forum users have complained about the
diminished availability of public chairpersons after the amendment to
the public arbitrator definition. FINRA also states that forum users
have complained of scheduling difficulties and additional costs
associated with traveling chairpersons (i.e., public chairpersons that
FINRA asks to travel to other hearing locations to expand the roster of
available public chairpersons for a given location), as well as out-of-
town arbitrators' lack of familiarity with local venue customs and
procedures.\24\ Moreover, FINRA states that it has had limited success
in enrolling new public chairpersons, and that the need for public
chairpersons could potentially surpass the availability of public
chairpersons who meet the qualifications under the existing Codes.\25\
---------------------------------------------------------------------------
\24\ See id.
\25\ See id.
---------------------------------------------------------------------------
Proposed Rule Change
FINRA is proposing to amend the eligibility requirements under the
Codes for arbitrators who seek to qualify as chairpersons. The
amendment would allow an attorney arbitrator to qualify for the
chairperson roster if he or she completes chairperson training and
serves as an arbitrator through award on at least one arbitration
administered by a self-regulatory organization where hearings are held,
instead of two arbitrations (as is currently required). FINRA is also
proposing to replace the bullets in Rules 12400 and 13400 with numbers
for ease of citation.
FINRA states that reducing the case experience requirement for
would-be arbitrators from two arbitrations to one arbitration could add
more than 270 attorney arbitrators across 59 of its 71 hearing
locations, potentially resulting in a nearly 30 percent increase in the
number of arbitrators who might be eligible to serve as public
chairpersons once they take chairperson training.\26\ FINRA also
believes that the proposed rule change would increase the availability
of local chairpersons for forum users, lowering instances in which
chairpersons must travel, and ameliorating parties' concerns regarding
out-of-town arbitrators.\27\
---------------------------------------------------------------------------
\26\ See id. at 61289.
\27\ See id.
---------------------------------------------------------------------------
III. Summary of Comments and FINRA's Response
The Commission received five (5) comment letters on the proposed
rule change,\28\ and a response letter from FINRA.\29\ Three commenters
supported the amendment,\30\ and two generally supported the amendment
while advocating for further action.\31\ FINRA's response to
commenters' concerns and suggestions are incorporated below.
---------------------------------------------------------------------------
\28\ See supra note 5.
\29\ See supra note 7.
\30\ See Caruso Letter, Bakhtiari Letter, and FSI Letter.
\31\ See PIABA Letter and GSU Letter.
---------------------------------------------------------------------------
Comment Letters in Support of the Proposal
As noted above, three commenters supported FINRA's proposed
amendments to the Codes. One commenter stated that the proposal would
``be a fair, equitable and reasonable approach that would facilitate
the increased appointment of local chairpersons to arbitration panels
and, at the same time, would reduce the necessity for the appointment
of out-of-state chairpersons.'' \32\ A second commenter supported the
proposed amendment on the ground that it ``would significantly increase
the available number of arbitrators included on the Chair roster and
represents an important step towards increasing the probability of
drawing local chairpersons in suburban or remote hearing locations.''
\33\ A third commenter supported the proposal based on its belief that
the requirement of a law degree and participation in one arbitration
through award are reasonable criteria for a public chair.\34\
---------------------------------------------------------------------------
\32\ See Caruso Letter.
\33\ See Bakhtiari Letter.
\34\ See FSI Letter.
---------------------------------------------------------------------------
Supportive Comment Letters Recommending Modifications to the Proposal
Two comment letters recommended modifications to the proposal,
while generally expressing support for the proposal. One commenter
stated that investors would ``benefit from a larger pool of qualified
public chairpersons'' and generally supported the proposed rule as ``a
positive step in regards to increasing the number of arbitrators in
proposed chair pools[.]'' \35\ Another commenter stated that it
``applaud[s] FINRA's decision to expand the public arbitrator chair
pool[.]'' \36\ However, both commenters raised additional concerns and
suggestions for the proposed amendment.
---------------------------------------------------------------------------
\35\ See PIABA Letter.
\36\ See GSU Letter.
---------------------------------------------------------------------------
Enhancing Transparency of the Arbitrator Selection Process
One commenter advocated for greater transparency regarding
arbitrators' backgrounds and qualifications, as well as greater
transparency in the arbitrator selection process generally in order to
improve investor confidence in FINRA arbitrators.\37\ According to this
commenter, FINRA's current disclosure system, which provides
information regarding arbitrators' education, employment history and
potential conflicts, is insufficient to eliminate the appearance of
impropriety and bias.\38\
---------------------------------------------------------------------------
\37\ See PIABA Letter.
\38\ Id.
---------------------------------------------------------------------------
In response, FINRA stated that it produces a disclosure report
reflecting the prior employment, educational history, and previous
arbitration awards for every potential arbitrator during the
appointment process.\39\ FINRA also requires arbitrators to either
certify the accuracy of the information in the disclosure report or
update the report when they are appointed to a case.\40\ In addition,
FINRA reminds arbitrators on a quarterly basis to review their
disclosure reports and revise them as needed. Moreover, FINRA stated
that it is revising its disclosure reporting system to alert parties of
the last time the arbitrator certified the accuracy of the information
contained therein.\41\
---------------------------------------------------------------------------
\39\ See FINRA Letter.
\40\ Id.
\41\ Id.
---------------------------------------------------------------------------
Use of Out-of-Town Arbitrators and Recruitment Initiatives
One commenter stated that the overall reduction in the number of
eligible chairpersons has reduced the pool of local chairpersons, and
caused FINRA to ask non-local chairpersons to travel to
[[Page 88722]]
multiple hearing locations.\42\ This commenter believes that the use of
non-local arbitrators has resulted in inconvenience, delay, and
additional costs to parties, and has led to a decrease in customer
awards because of non-local arbitrators' purported bias in favor of the
industry.\43\ For these reasons, the commenter suggested that, to the
extent possible, FINRA should eliminate the use of non-local
arbitrators and increase the size of regional pools--especially where
out-of-state arbitrators regularly appear on public and chair-qualified
ranking lists.\44\
---------------------------------------------------------------------------
\42\ See PIABA Letter.
\43\ See id.
\44\ See id.
---------------------------------------------------------------------------
In its response, FINRA stated that it uses arbitrators in
neighboring hearing locations ``to ensure an effective ratio of
available arbitrators to open cases in each location[.]'' \45\ For
example, ``as an interim measure, FINRA took steps to bolster the pool
of arbitrators in smaller hearing locations that were impacted by the
amended public arbitrator definition by asking chairs from larger
hearing locations . . . if they would be willing to serve[.]'' \46\
FINRA also stated, however, that it agrees that it should increase the
size of its public arbitrator pool, and stated that it has been
``actively recruiting new arbitrators, paying particular attention to
locations with the greatest need.'' \47\
---------------------------------------------------------------------------
\45\ See FINRA Letter.
\46\ Id.
\47\ Id.
---------------------------------------------------------------------------
Additional Chairperson Training and Mentorship
One commenter expressed the concern that the proposed rule change
might sacrifice chairperson quality at the expense of chairperson
quantity, as ``quality pools are paramount to a fair and equitable
arbitration proceeding, as well as the public investors' confidence in
the overall arbitration process.'' \48\ The commenter therefore
recommended, in part, that FINRA adopt a ``Chairperson Mentor program''
to increase the quality of chair-qualified arbitrators.\49\
---------------------------------------------------------------------------
\48\ See PIABA Letter.
\49\ Id.
---------------------------------------------------------------------------
Another commenter similarly asserted that, by expanding chairperson
eligibility, the proposed rule change would reduce arbitrators'
exposure to live proceedings prior to serving as a chair.\50\ To
address this reduction in experience, the commenter proposed that FINRA
``include in the Office of Dispute Resolution Chairperson Training a
module or section that specifically addresses the procedural and
substantive issues that regularly arise in live arbitration
proceedings.'' \51\ Alternatively, the commenter proposed that FINRA
require arbitrators to observe a live or mock proceeding before
becoming eligible to serve as a public chair.\52\
---------------------------------------------------------------------------
\50\ See GSU Letter.
\51\ Id.
\52\ Id.
---------------------------------------------------------------------------
In response, FINRA stated that, earlier this year, it implemented a
chairperson mentorship program to facilitate interaction between new
chairpersons and experienced chairpersons.\53\ In addition, in November
2016, FINRA provided arbitrators access to online workshops that
address issues chairpersons regularly encounter.\54\ Moreover, FINRA
stated that it regularly invites qualified arbitrators to complete
chairperson training.\55\
---------------------------------------------------------------------------
\53\ See FINRA Letter.
\54\ Id.
\55\ Id.
---------------------------------------------------------------------------
Simplifying the Arbitrator Application Process
One commenter expressed concern that the arbitrator application
process is ``burdensome and intimidating and surely drives away many
potential arbitrators which further weakens the number and quality of
arbitrators available in the FINRA system.'' \56\ Accordingly, PIABA
suggested that FINRA simplify the arbitrator application process.\57\
---------------------------------------------------------------------------
\56\ See PIABA Letter.
\57\ Id.
---------------------------------------------------------------------------
FINRA responded that, in 2017, it plans to replace the ``time-
consuming'' ``Securities Disputes Experience'' section of the
arbitrator application with a section that allows applicants to explain
their securities disputes expertise and skills in narrative form.\58\
FINRA believes that this change will simplify the arbitrator
application process.\59\
---------------------------------------------------------------------------
\58\ See FINRA Letter.
\59\ Id.
---------------------------------------------------------------------------
Revisiting the ``Public Arbitrator'' Definition
One commenter cited the 2015 amendments to the definition of
``Public Arbitrator'' as a significant contributor to the reduction in
the chairperson roster overall and disproportionately for claimants
with smaller claims.\60\ For instance, GSU stated that there are only
40 chair-qualified arbitrators in its primary hearing location,
Atlanta.\61\ The commenter thus recommended that FINRA revisit the 2015
amendments to the public arbitrator definition as a means for
increasing the chairperson roster.
---------------------------------------------------------------------------
\60\ See GSU Letter.
\61\ Id.
---------------------------------------------------------------------------
In response, FINRA stated that it had revisited the 2015 amendments
to the arbitrator definitions and determined not to change the public
arbitrator definition, as FINRA deemed it important for public
arbitrators to have no significant affiliation with the financial
industry.\62\ However, FINRA noted that a gap exists between the public
and non-public arbitrator definitions, which excludes otherwise
qualified individuals from service as arbitrators--often because of
family or co-workers' affiliations.\63\ According to FINRA, in
September 2016, its Board of Governors authorized FINRA to file with
the Commission proposed amendments to Rules 12100 and 13100 of the
Codes to revise the non-public arbitrator definition.\64\ These
amendments would define a non-public arbitrator as a person who is
otherwise qualified to serve as an arbitrator, and is disqualified from
classification as a public arbitrator.\65\ By closing this gap, FINRA
asserted that it could expand its roster of available arbitrators.\66\
---------------------------------------------------------------------------
\62\ See FINRA Letter.
\63\ Id.
\64\ Id.
\65\ Id.
\66\ Id.
---------------------------------------------------------------------------
IV. Discussion and Commission Findings
The Commission has carefully considered the proposal, the comments
received, and FINRA's response to the comments. Based on its review of
the record, the Commission finds that the proposed rule change is
consistent with the requirements of the Exchange Act and the rules and
regulations thereunder applicable to a national securities
association.\67\ In particular, the Commission finds that the proposed
rule change is consistent with Section 15A(b)(6) of the Exchange
Act,\68\ which requires, among other things, that FINRA's rules be
designed to prevent fraudulent and manipulative acts and practices, to
promote just and equitable principles of trade, and, in general, to
protect investors and the public interest.
---------------------------------------------------------------------------
\67\ In approving the proposed rule change, the Commission has
also considered its impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
\68\ 15 U.S.C. 78o-3(b)(6).
---------------------------------------------------------------------------
As discussed above, the proposal would amend Rules 12400 and 13400
of the Codes to allow an attorney arbitrator to qualify for the
chairperson roster if he or she completes chairperson training and
serves as an arbitrator through award on at least one arbitration
administered by a self-regulatory
[[Page 88723]]
organization where hearings are held, instead of two arbitrations (as
is currently required). It would also replace the bullets in Rules
12400 and 13400 with numbers for ease of citation.
The Commission has considered the five (5) comment letters received
on the proposed rule change,\69\ along with FINRA's response to the
comments.\70\ The Commission acknowledges the supportive commenters'
positions that the proposal would ``be a fair, equitable and reasonable
approach that would facilitate the increased appointment of local
chairpersons to arbitration panels,'' \71\ that it ``would
significantly increase the available number of arbitrators included on
the Chair roster and represents an important step towards increasing
the probability of drawing local chairpersons in suburban or remote
hearing locations,'' \72\ and that the requirement of a law degree and
participation in one arbitration through award are reasonable criteria
for a public chair.\73\ However, the Commission also acknowledges
commenters' concerns and recommended modifications to the proposal.\74\
These concerns and modifications are discussed below.
---------------------------------------------------------------------------
\69\ See supra note 5.
\70\ See supra note 7.
\71\ See Caruso Letter.
\72\ See Bakhtiari Letter.
\73\ See FSI Letter.
\74\ See PIABA Letter and GSU Letter.
---------------------------------------------------------------------------
Enhancing Transparency of the Arbitrator Selection Process
The Commission acknowledges the commenter's concern that FINRA's
current disclosure system does not always eliminate the appearance of
impropriety and bias in the FINRA arbitration forum, and agrees that
transparency in the arbitrator selection process improves investor
confidence in FINRA arbitrators.\75\ However, the Commission believes
that FINRA's disclosure reporting system provides parties with a basis
on which to identify potential arbitrator conflicts and biases.
Moreover, the Commission believes that by reminding arbitrators to
update their disclosure reports, and notifying parties of the last date
an arbitrator certified the accuracy of the disclosure report, FINRA
will further help ensure that parties have up-to-date information on
which to base their arbitrator selections.
---------------------------------------------------------------------------
\75\ See PIABA Letter.
---------------------------------------------------------------------------
Use of Out-of-Town Arbitrators and Recruitment Initiatives
The Commission acknowledges the commenter's concerns regarding the
inconvenience, delay, and additional costs caused by the use of non-
local arbitrators.\76\ However, given the reported insufficient levels
of local chairpersons in certain hearing locations,\77\ the Commission
does not believe it is feasible or practical to eliminate the use of
non-local arbitrators, as the commenter suggested.\78\ Instead, the
Commission acknowledges the necessity of FINRA's policy of asking
public chairs from larger, geographically proximate hearing locations
to serve as chairpersons in regions with insufficient levels of local
qualified chairpersons. The Commission additionally supports FINRA's
increased arbitrator recruitment efforts, and anticipates that such
efforts will eventually result in a broader, more diverse pool of
arbitrator candidates.
---------------------------------------------------------------------------
\76\ Id.
\77\ See FINRA Letter.
\78\ See PIABA Letter.
---------------------------------------------------------------------------
Additional Chairperson Training and Mentorship
With regard to commenters' concerns that the proposed amendment
might decrease the quality and experience of arbitrator chairpersons at
the expense of increasing the quantity of chairpersons, the Commission
acknowledges their recommendation that a mentor program or additional
trainings should be provided to chairpersons.\79\ The Commission
generally believes that FINRA's implementation of a chairperson
mentorship program, as well as its increased provision of and focus on
arbitrator trainings should effectively address the commenters'
concerns.
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\79\ See PIABA Letter and GSU Letter.
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Simplifying the Arbitrator Application Process
The Commission acknowledges the concern expressed regarding FINRA's
purportedly burdensome and intimidating arbitrator application process,
and the potential deterrent effect the process might have on would-be
arbitrator applicants.\80\ However, the Commission believes that a
rigorous application process is necessary to verify the qualifications
of arbitrator candidates. Furthermore, the Commission expects that
FINRA's use of a narrative application section where applicants can
explain their securities disputes expertise and skills will simplify
the arbitrator application process without degrading the value of the
elicited information, thereby addressing the commenter's concern.
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\80\ See PIABA Letter.
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Revisiting the ``Public Arbitrator'' Definition
The Commission acknowledges the commenter's suggestion that FINRA
reconsider the 2015 amendments to the public arbitrator definition in
an effort to combat the resulting reduction in the chairperson
roster.\81\ However, at the time the Commission approved the 2015
amendments to the public arbitrator definition, the Commission
determined that the approach proposed by FINRA was appropriate and
designed to protect investors and the public interest, consistent with
Section 15A(b)(6) of the Exchange Act and the rules and regulations
thereunder.\82\ Accordingly, the Commission also gives due regard to
FINRA's decision not to amend the definition of public arbitrator at
this time.\83\ Nevertheless, the Commission will give appropriate
consideration to any proposed amendments to FINRA Rules 12100 and 13100
to revise the non-public arbitrator definition to eliminate any gaps in
the Codes' arbitrator classifications that could expand its roster of
available arbitrators.
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\81\ See GSU Letter.
\82\ See 80 FR 11695 at 11704-11705.
\83\ See FINRA Letter.
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Taking into consideration the comments and FINRA's responses, the
Commission finds that the proposal is consistent with the Exchange Act.
Specifically, the Commission believes that the proposal will help
protect investors and the public interest by, among other things,
broadening the roster of available arbitrator chairpersons, while
preserving the quality of arbitrators who would serve as chairpersons.
Furthermore, the Commission believes that FINRA's responses, as
discussed in more detail above, appropriately addressed commenters'
concerns and adequately explained FINRA's reasons for declining to
modify its proposal. Accordingly, the Commission believes that the
approach proposed by FINRA is appropriate and designed to protect
investors and the public interest, consistent with Section 15A(b)(6) of
the Exchange Act and the rules and regulations thereunder.
V. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Exchange Act,\84\ that the proposed rule change (SR-FINRA-2016-033) be,
and hereby is, approved.
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\84\ 15 U.S.C. 78s(b)(2).
[[Page 88724]]
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For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\85\
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\85\ 17 CFR 200.30-3(a)(12).
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Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2016-29385 Filed 12-7-16; 8:45 am]
BILLING CODE 8011-01-P